114 T.C. No. 32
UNITED STATES TAX COURT
JOHN W. AND FAYTHE A. MILLER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12310-98. Filed June 23, 2000.
Ps claimed dependency exemptions on their 1996
joint Federal income tax return without furnishing
SSN’s for their children, as required under sec.
151(e), I.R.C. Ps seek relief from the SSN requirement
because of their religious beliefs in opposition to
using SSN’s. Held: the SSN requirement is the least
restrictive means of achieving the Government’s
compelling interests in implementing the Federal tax
system in a uniform, mandatory way and in detecting
fraud in regard to dependency exemptions. Accordingly,
neither the Free Exercise Clause of the First Amendment
to the Constitution nor the Religious Freedom
Restoration Act of 1993, Pub. L. 103-141, sec. 2, 107
Stat. 1488, provides a basis for excepting Ps from the
SSN requirement.
John W. and Faythe A. Miller, pro se.
Elizabeth A. Owen, for respondent.
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